A/HRC/29/33 international levels (see E/CN.4/2003/58, para. 9). The then Special Rapporteur explored those three objectives by way of two interrelated themes: the right to health in relation to poverty, focusing on health-related Millennium Development Goals; and the right to health and the determinants of discrimination and stigma. 18. Throughout his tenure, the former Special Rapporteur Paul Hunt distinguished between judicially oriented and policy-oriented processes. Although the two approaches are closely related and mutually reinforcing, the former aims to promote and protect the right to health via the drawing up of rules and principles derived from case law, building up general guidance from the lessons learned via the resolution of particular disputes. Judicial and quasi-judicial forms of accountability exemplify this approach. The former Rapporteur also emphasized that the policy approach is not a soft option, on the contrary, it places a legal obligation on policymakers to ensure that a health system includes comprehensive health plans encompassing the public and private sectors, outreach programmes for the disadvantaged and numerous other features demanded by the right to health. The policy approach is not without accountability: it requires that policymakers are subject to judicial and non-judicial forms of review. 19. The work of the mandate has addressed the challenges and opportunities related to progressive realization of the right to health and those obligations that have immediate effect. With regard to resource constraints and progressive realization, international human rights law recognizes that the realization of the right to health is subject to progressive realization based on resource availability. That is why a higher standard is required of a developed State today than is required of a developing State. However, all States are obliged to realize progressively the right to the highest attainable standard of health. In order to measure progress, indicators and benchmarks need to be identified, and the work of the first mandate holder in that regard continues to be very useful (see A/58/427 and E/CN.4/2006/58). 20. Previous mandate holders have given details of the challenges and opportunities that arise from the right to available, accessible, acceptable and good-quality health-care services. In that regard, health-care systems are at the heart of the right to health and act as a fundamental building block of sustainable development, poverty reduction and economic prosperity (A/HRC/7/11, para. 12). The principles embodied in the Alma-Ata Declaration on Primary Health Care (1978) and the Ottawa Charter for Health Promotion (1986) remain relevant today. 21. The work of the mandate has also addressed the challenges for States in realizing their obligations to ensure that adequate funds are available for health in national budgets, to safeguard an equitable allocation of health resources and to enhance international cooperation to promote sustainable international funding for health (see A/67/302). 22. The work of the Special Rapporteur’s predecessors has highlighted that one of most important obligations of immediate effect related to right to health is the duty to avoid discrimination.1 This means that, even in the presence of resource constraints, that obligation should not be subject to progressive realization. Discrimination and stigma are considered as social determinants in the enjoyment of the right to health, as social inequalities and exclusion shape health outcomes and contribute to increasing the burden of disease borne by marginalized groups. In addition, some health conditions, such as mental health or HIV/AIDS, may involve exposure to compounded forms of discrimination and reinforce existing inequalities (E/CN.4/2003/58, para. 59). 1 See Committee on Economic Social and Cultural Rights, general comment No. 14 (2000) on the right to the highest attainable standard of health, para. 43. 5